/ " ''-"i., UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 8 

1595 Wynkoop Street 

DENVER, CO 80202-1129 

'• -v ,..,.,- ' Phone 800-227-8917 

http://www.epa.gov/region08 

Ref: 8P-AR »« 1 2 '"'"> 

Brian Gustafson, Administrator 

Air Quality Program 

South Dakota Department of Environment and Natural Resources 

523 East Capitol Avenue 

Pierre, SD 57501-3182 

RE: EPA Region 8 Comments on January 15, 2010 

Draft Regional Haze SIP (FLM Consultation 

Version) 

Dear Brian: 

EPA has completed a preliminary review of South Dakota's January 15, 2010 draft 

Regional Haze State Implementation Plan (SIP), as received via email through your Federal Land 

Manager (FLM) consultation process. Our comments and questions are detailed in the Enclosure 

to this letter. 

We understand that you intend to consider all comments received on this FLM 

consultation version of the Regional Haze SIP prior to preparing the documents for your public 

notice and comment process. The final draft of the SIP, which will include a summary of the 

FLMs' comments and your responses, will then undergo a broader public hearing process prior to 

adoption and submission to EPA. We emphasize that we will only reach a final conclusion 

regarding the adequacy of South Dakota's Regional Haze SIP when we act on the South Dakota 

Regional Haze SIP revision through our own public notice and comment rulemaking. 

We want to acknowledge your efforts in developing this SIP and working with us to 

resolve concems related to subject-to-BART modeling for Big Stone I. This effort has helped to 

narrow the issues significantly; however, important issues remain. Our comments are intended to 

assist you in revising the draft SIP before you begin your public hearing process. Please note that 

our most serious concems are summarized at the beginning of the Enclosure. 

As you are aware. South Dakota received a finding of failure to submit its Regional Haze 

SIP by the required deadline. As a result, a 2-year clock was initiated for EPA to fully approve a 

SIP or promulgate a Federal Implementation Plan by January 15, 2011. In order to meet this 

deadline, we continue to advise you to submit the South Dakota Regional Haze SIP in a timely 

manner. Please do not hesitate to contact me with any concems related to this timeline. 
We have appreciated working with you during the review of this FLM consultation 

version of the draft Regional Haze SIP and look forward to continued communications during the 

public hearing process. If you have any questions on EPA's comments, please contact me at 

303-312-6434, or your staff may contact Gail Fallon at 303-312-6281 or Amy Piatt at 

303-312-6449. 

Sincerely, 

Gallic A. Videtich, Director 

Air Program 

Enclosure 

cc: Chris Shaver, NPS 

Sandra Silva, USFWS 

Thomas Dzomba, USFS 

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®. Printed on Recycled Paper 
ENCLOSURE 

EPA Region 8 Preliminary Comments on the January 15,2010 Draft Regional Haze SIP 

(FLM Consultation Version) 

Summary of Major Concerns - (see detailed comments for more information): 

• No justification for separate startup/shutdown limits for PM, SO2, and NO.x. See 

comments #18-20 below. 

• No details on how the BART emission limits vsdll be made enforceable as a practical 

matter. See comments #1 and #21 below. 

• No identification of the number of years to reach natural conditions as required when the 

Reasonable Progress Goal is less than the Uniform Rate of Progress. See comment #23 

below. 

• No 4-factor Reasonable Progress analysis. See comment #24 below. 

• No smoke management plan even though fire is identified as a major contributor. See 

comment #31 below. 

Detailed Comments; 

1. Executive Summary, pp. viii-ix: 

(A) The BART emission limits, compliance schedules, monitoring, recordkeeping, and 

compliance determining methods for Big Stone I must be specified in the text of the Regional 

Haze SIP or in a permit that is incorporated into the SIP. You note that you intend to 

establish the appropriate averaging times, compliance verification procedures, and 

recordkeeping and reporting requirements in an air quality construction permit. Since this 

document is not included in this draft SIP, we would like to work with you to ensure that 

these requirements are adequately addressed in the SIP. Note that the public notice for the 

Regional Haze SIP needs to include notification that an air quality permit to address BART 

requirements is incorporated as part of the SIP. Additionally, with MDU Resources Group's 

November 2, 2009 announcement that Big Stone II will not be built, does SD DENR plan to 

amend and/or revoke the existing permit provisions in order to reflect the Company's 

announcement and the forthcoming BART determination, and what is the timeline for doing 

so? 

(B) The last sentence references a Chapter 12 that was not included in this draft FLM 

consultation version of the SIP; therefore, we were unable to review and comment on it. 

2. Chapter 1, Introduction, p. 1: 

(A) Please clarify that the 1977 Clean Air Act Amendments and EPA's 1980 reasonable 

attributable visibility impairment regulations addressed visibility impairment that was caused 

or contributed to by one or a small group of sources. 

(B) Please revise the date for delegation of the Prevention of Significant Deterioration (PSD) 

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program to July 6, 1994. The September 15, 1994 date is simply when EPA provided notice 

that the delegation had been granted as of July 6,1994. 

3. Sections 3.1, Baseline Visibility Conditions, and 3.2, Natural Visibility Conditions, 

pp.11-16: 

(A) It appears that Appendix A will contain the IMPROVE data used to determine baseline 

visibility; however, Appendix A was not included with this draft FLM consultation version of 

the SIP. 

(B) Based on our review of WRAP's Visibility Information Exchange Web System (VIEWS) 

and information from the USFS, it appears that there are some errors in the baseline and 

natural background figures provided in Tables 3-1, 3-5, and 3-7. We understand that the 

USFS has raised these concerns with you and requested the opportunity to discuss; therefore, 

we will look for these figures to be revised accordingly. Please note that EPA's default 

values for natural conditions must be used in the current SIP and any refinements deferred to 

future planning periods. 

(C) Table 3-6 addresses the westem natural conditions, but the footnotes refer to Trijonis 

estimates for both East and West. The Trijonis estimates for the East do not need to be 

included. 

(D) A column must be added to Table 3-7 to highlight the deciview improvement required 

for both best and worst days. 

4. Figure 3-11, Uniform Rate of Progress, p. 17: This figure has been omitted. Perhaps with its 

inclusion, our following comment would be addressed. 

5. Table 3-8, Annual Uniform Rate of Improvement, p. 18: This table needs to include the 

uniform rate of improvement for the 1^' planning period (2004-2018) for the most and the 

least impaired days, rather than leaving it to the reader to calculate fi-om the annual numbers 

provided. 

6. Figure 3-12, Uniform Rate of Improvement, pp. 18-19: For both Class I areas, we could not 

determine the source of the 2018 numbers. For Badlands, it appears that the 2018 uniform 

rate of progress should be 14.89 dV (based on the 14 year 1^' planning period) instead of 

15.04 dV, and for Wind Cave, 13.94 dV instead of 14.01 dV. In addition, once the baseline 

and natural background values are revised per our comment #3 above, these values will need 

to be recalculated. 

7. Section 5.0, Source Apportionment, pp. 37-58: 

(A) Secfion 5.1, Air Emission Inventory, pp. 37-38: In general, the WRAP inventories 

utilized are adequate for this planning period. However, there are some known shortcomings 

with the WRAP inventories, including the oil and gas emissions estimates. Please note that 

we would expect future reviews of the South Dakota Regional Haze SIP to rely on the most 

current, updated emissions inventory. 
(B) Pages 39 & 43: Please elaborate on the "compliance initiative" related to VOC emissions 

from secondary oil and gas production in northwestem South Dakota. The draft document 

indicates that the initiative identified emissions that needed to be addressed, and it appears 

emission control devices were installed. What state mechanisms are in place to ensure these 

four thermal oxidizers are operating at greater than 98% control? 

(C) Tables 5-1, 5-2, and 5-4, pp. 40-44: In Tables 5-1 and 5-2, the baseline VOC emissions 

from oil and gas are identified as 33,721 tons, while the 2018 projected VOC emissions fi"om 

oil and gas are shown as 562 tons in Table 5-4. According to the WRAP Technical Support 

System (TSS), the corresponding baseline and projected VOC emissions from oil and gas are 

288 tons and 562 tons, respectively. This large discrepancy between South Dakota's reported 

numbers and the WRAP TSS must be explained in greater detail in the SIP. In addition, 

please explain whether these emissions from secondary oil and gas production were used for 

modeling and reasonable progress purposes. We also note that Table 5-1 provides the 

baseline SO2 emissions fi'om area sources as 10,159 tons, while Table 5-2 lists 1,071 tons 

from the same source. This very substantial difference is consistent with values reported on 

the WRAP TSS; however, no explanafion is provided. The SIP text must provide 

clarification. Finally, there appears to be a typographical error in the footnotes to Table 5-4 -

two footnotes labeled "3." 

(D) Tables 5-6 and 5-7, p. 46: We note some discrepancies compared with what was 

included in other state plans. In order to ensure consistency with other states' assumptions it 

would be prudent to verify their emission inventory numbers. For example, the North Dakota 

draft plan lists North Dakota NOx emissions for 2018 at 171,566 tons, but the South Dakota 

draft plan lists North Dakota NOx emissions at 187,032 tons for 2018. 

(E) Last paragraph, p. 54, and second paragraph, p. 56: There may be typographical errors, 

but in any case the text is not consistent with the figures which show a slight change between 

2002 and 2018 for both the least and most impaired days. Please clarify. 

(F) First paragraph, 2"** to last sentence, p. 58: The text regarding Montana's organic carbon 

mass contribution must be clarified to read that, "Natural fire related organic carbon mass 

generated in Montana contributes approximately 34% of the organic carbon mass in Badlands 

National Park." 

Section 6.1, BART-Eligible Sources, pp. 70-71: 

(A) The definition of "Date of Reconstruction" does not quite match the Federal definition 

and must be revised. The Federal definition is for the date of operation, construction, or 

reconstruction and applies to sources that were not in operation before August 7, 1962 and in 

existence as of August 7, 1977 with any reconstruction occurring during the August 7, 1962 

to August 7, 1977 time period. 

(B) The last sentence of the definition for "Potential to Emit" contains a typographical errorshould be 26 categories. 

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9. Section 6.1.2, Pete Lien, pp. 72-73: 

(A) There appears to be a typographical error in the T^ sentence of the first paragraph -

should be worded as "not in operation prior to August 7, 1962..." 

(B) Because there is a rotary kiln (Unit 4a) producing lime within the Pete Lien facility, Pete 

Lien is classified as a lime plant according to the definition in 40 CFR Part 60, Supart HH. 

The fact that the unit in question under BART is a vertical kiln does not exclude Pete Lien 

from the lime plant category, since it does have a rotary kiln producing lime within the plant. 

Therefore, it was the appropriate decision to include Pete Lien in the WRAP 

subject-to-BART modeling analysis. We were unaware that you had determined there were 

errors in the modeling inputs and a need for a re-run. You note that the vertical kiln was 

shutdown and dismantled in 2009 prior to completion of a modeling re-run. However, the 

November 12, 2008 Title V permit for Pete Lien still includes the vertical kiln, and there has 

not been a permit modification to address any such dismantling and closure. Either the 

permit needs to be modified to reflect this change in status of the vertical kiln, or the 

modeling needs to be re-run to correct the input errors and accurately determine whether Pete 

Lien is subject to BART. 

10. Section 6.2, Otter Tail Power Company's Modeling Results, pp. 75-77: We note that the 

specific version of CALPUFF, coordinate grid points, wind field options, terrain, dispersion 

options, receptor coordinates, plume characteristics and other model parameters approved by 

the DENR were used for modeling. The DENR approved protocol (/. e.. the August 31, 2009 

Revised Modeling Protocol for a BART Assessment of the Big Stone I Coal-Fired Power 

Plant) is acceptable to EPA; however, the modeling input and output files need to be 

incorporated into the SIP for documentation and public review. 

11. Section 6.3.2.4, Sulfiar Dioxide Control Technology Impacts, p. 83: Footnote number 3 

indicates a baseline level of 18,000 tons of S02/year; however, according to Table 6-1 on 

p. 71, the baseline was 19,863 tons/year. This larger baseline figure results in an 81% 

emission reducfion for the 3'^'' option, as opposed to 90% with the 18,000 tons/year figure. 

Please explain how the 18,000 tons/year SO2 baseline figure was obtained. 

12. Section 6.3.3.2, Technically Feasible Nitrogen Oxide Control Technologies, pp. 85-86: At 

this time, we have not completed a thorough review of your comments regarding commercial 

availability and technical feasibility of the various NOx control technologies listed. 

Therefore, we may have additional comments on this section during the public comment 

period. 

13. Table 6-9, p. 87: Footnote 5 references a 1999 EPA Technical Bulletin on NOx controls as 

justification for the 35%-90% control efficiency range for the top three options. The large 

range in EPA's bulletin is due to inclusion of SCR, selecfive non-catalytic reducfion (SNCR), 

and fuel rebuming for wet-bottom boilers. It is well documented that SCR achieves the high 

end of the range. The EPA bullefin also lists a 30%-70% control efficiency for a group of 

temperature-reducing controls, including over-fire air. Therefore, the proposed BART 

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determination of SCR plus separated over-fire air (SOFA) should be better than the 90% 

control efficiency of SCR alone. It is not clear from the SIP text how the proposed emission 

limit was calculated; however, according to EPA's Acid Rain Database, Big Stone I NOx 

emissions have averaged 0.77 Ib/MMBtu over the last five years. Assuming a control 

efficiency greater than 90% should result in a limit lower than the proposed 0.1 Ib/MMBtu. 

14. Section 6.3.3.4, Nitrogen Oxide Control Technology Impacts, p. 87: We assume you are 

relying on Otter Tail's analysis of estimated costs, which relied on the CUECost model. 

While we are satisfied with the control technology conclusions of your NOx BART 

determination (i. e., SCR plus SOFA), in general we do not recommend relying on the 

CUECost model. According to the BART Guidelines, in order to maintain and improve 

consistency, cost estimates must be based on the OAQPS Control Cost Manual. 

15. Table 6-10, p. 88: Footnote 3 contains typographical errors - should be nitrogen oxides. In 

addition, similar to comment #11 above, it is tmclear how the baseline level of 

18,000 tons/year was obtained. According to Table 6-1, p. 71, baseline NOx emissions were 

17,179 tons/year. The larger baseline figure results in an 89% emission reduction for the T' 

option, as opposed to 93% with the 17,179 tons/year figure. As stated above in comment 

#13, a control efficiency greater than 90% is appropriate for the proposed SCR plus SOFA 

controls. Please explain how the 18,000 tons/year NOx baseline figure was obtained. 

16. Section 6.3.4, Visibility Impact Evaluations, 2"^ paragraph, p. 89: Again, the text refers to 

Big Stone 1 baseline emissions of 18,000 tons SO2 and 18,000 tons NOx. Please explain how 

these numbers were obtained. 

17. Table 6-12, p. 89: According to Footnote 2 of Table 6-12, the rounded modeling values 

shown in the parentheses were used to compare with the subject-to-BART threshold, but 

actually, the unrounded modeled value must be used for determining whether a source 

exceeds the threshold. 

18. Section 6.3.5.1, Particulate Matter BART Recommendafion, p. 95: 

(A) We assume DENR's proposed particulate matter BART limit of 0.012 Ib/MMBtu is on a 

30-day rolling average basis, as required. Please clarify in the SIP. 

(B) While we agree that a baghouse is the top particulate control technology, what is the 

justification for proposing a separate hourly startup/shutdown limit? The SIP must document 

the need for such a separate limit, as well as whether the selected value represents BART. 

Has DENR evaluated potential impacts of the separate startup/shutdown limit on visibility? 

The BART Guidelines contemplate pounds per million Btu limits that apply continuously, 

with a 30-day rolling average period to accommodate, among other things, potential shortterm fluctuations in the emissions rate that may result during startup, shutdown, and other 

conditions. Presumably, your proposed 30-day rolling average limit already includes some 

margin of safety for operational variation. If you are able to justify the separate limits, we 

would work closely with you as you draft appropriate permit language to help ensure SIP 

approvability related to determining compliance with the normal 30-day rolling average limit 

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and the hourly startup/shutdown limit. For example, in calculating 30-day averages, how will 

days be accounted for that include some, but not all, hours of startup/shutdown? 

19. Secfion 6.3.5.2, Sulfur Dioxide BART Recommendafion, pp. 96-97: 

(A) We assume DENR's proposed SO2 BART limit of 0.09 Ib/MMBtu is on a 30-day rolling 

average basis, as required. Please clarify in the SIP. 

(B) As noted in comment #18 above, justification for proposing a separate lb/hour limit for 

periods of startup and shutdown must be provided. The SIP must document the need for such 

a separate limit, as well as whether the selected value represents BART. Has DENR 

evaluated potential impacts of the separate startup/shutdown limit on visibility? The BART 

Guidelines contemplate pounds per million Btu limits that apply continuously, with a 30-day 

rolling average period to accommodate, among other things, potential short-term fluctuations 

in the emissions rate that may Result during startup, shutdown, and other conditions. 

Presumably, your proposed 30-day rolling average limit already includes some margin of 

safety for operational variation. If you are able to justify the separate limits, we would work 

closely with you as you draft appropriate permit language to help ensure SIP approvability 

related to determining compliance with the normal 30-day rolling average limit and the 

hourly startup/shutdown limit. For example, in calculating 30-day averages, how will days 

be accounted for that include some, but not all, hours of startup/shutdown? 

20. Section 6.3.5.3, Nitrogen Oxide BART Recommendation, pp. 97-98: 

(A) Regarding the term "threshold" in reference to $1500/ton for NOx removal, EPA's 

position is that the NOx presumptive limits were established based on the relatively low cost 

of less than $l500/ton for the majority of large EGUs. There is no bright line regarding cost 

effectiveness and each determination must be made taking into account a full five factor 

BART analysis. In addition, although Big Stone I has a capacity less than 750 MW, it is 

greater than 200 MW and operating without post-combustion controls. Per the BART 

Guidelines, it is reasonable to assume that SCR is generally cost-effective on large cyclone 

units. See 70 FR 39171, Jufy 6, 2005. 

(B) Please clarify that DENR's NOx BART determination is SCR plus SOFA at 

0.10 Ib/MMBtu on a 30-day rolling average. 

(C) As noted in comments #18-19 above, justification for proposing a separate lb/hour limit 

for periods of startup and shutdown must be provided. The SIP must document the need for 

such a separate limit, as well as whether the selected value represents BART. Has DENR 

evaluated potential impacts of the separate startup/shutdown limit on visibility? The BART 

Guidelines contemplate pounds per million Btu limits that apply continuously, with a 30-day 

rolling average period to accommodate, among other things, potential short-term fluctuations 

in the emissions rate that may result during startup, shutdown, and other conditions. 

Presumably, your proposed 30-day rolling average limit already includes some margin of 

safety for operational variation. If you are able to justify the separate limits, we would work 

closely with you as you draft appropriate permit language to help ensure SIP approvability 

related to determining compliance with the normal 30-day rolling average limit and the 
hourly startup/shutdown limit. For example, in calculating 30-day averages, how will days 

be accounted for that include some, but not all, hours of startup/shutdown? 

21. Section 6.4, BART Requirements, p. 99: According to your proposed revisions to the 

South Dakota Administrative Rules, Chapter 74:36:21:10, a permit modification will be 

required for your BART determination on Otter Tail's Big Stone I. Without seeing the 

details of such permit, it is difficult to determine whether this section of the SIP adequately 

addresses requirements for enforceability, including appropriate averaging times, compliance 

verification procedures, and recordkeeping and reporting requirements, and proper operation 

and maintenance procedures. As noted in comment #1 above, these requirements must be 

specified either in the text of the Regional Haze SIP or in a permit that is incorporated into 

the SIP. 

22. Section 7.1, State and Federal Rules, pp. 100-101: Please clarify that although some of the 

cited Administrative Rules of South Dakota (ARD) control emissions of pollutants that 

ultimately contribute to visibility impairment, they were not written specifically to address 

visibility impairment. 

23. Table 7-1 and Section 7.2.1, BreakdouTi of CMAQ Modeling Results, pp. 102-103: We were 

unable to determine if 16.50 dv for Badlands and 15.28 dv for Wind Cave are your 

Reasonable Progress Goals (RPG). These numbers don't quite match with those shown in 

Figure 8-1. Please clarify and document how the numbers were obtained. Also, the SIP must 

include the dv difference between the baseline and natural conditions for the best and worst 

days for the l" planning period per 40 CFR 51.308(d)(2)(iv)(A). Finally, the SIP must 

provide the number of years necessary to reach natural conditions, as required by 

40 CFR 51.308(d)(l)(ii) when the RPG is less than the uniform rate of progress (URP). 

24. Section 7.2.2, Four Factor Analysis, p. 104: DENR's determination that a four-factor 

analysis is not warranted at this time is not acceptable. A four-factor analysis must be 

completed in establishing the RPGs for Class I areas impacted by South Dakota emissions, as 

well as in justifying a RPG that is less than URP. While we realize that the emissions 

reductions proposed under BART for Big Stone I will provide significant emissions 

reductions in South Dakota, remaining sources must be considered under Reasonable 

Progress. For example, are there any further reductions that could be obtained from 

GCC Dacotah, Ben French, or Pete Lien? What about potential impacts from the close 

proximity of Rapid City to Badlands? A simple Q/d analysis can provide a starting point. It 

may be reasonable for DENR to conclude, upon completion of an adequate four-factor 

analysis, that additional controls under Reasonable Progress are not warranted in this 

planning period. However, such a determination cannot be made without the analysis. 

Perhaps information from the WRAP'S May 19, 2009 drafl Supplementary Infonnation for 

Four-Factor Analyses for Selected Individual Facilities in South Dakota, and WRAP's 

May 4, 2009 draft Supplementary Information for Four Factor Analyses by WRAP States, can 

be utilized to address some of the Reasonable Progress analysis requirements. If so, our 

August 12, 2009 comments on the draft WRAP reports must be taken into account. 

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25. Section 8.0, Long Term Strategy, pp. 104-105: According to 40 CFR 51.306(c), the State 

must revise its plan to provide for a coordinated long-term strategy for addressing both 

reasonably attributable and regional haze visibility impairment, and future coordinated 

long-term strategies must be submitted consistent with the schedule for periodic progress 

reports set forth in 40 CFR 51.308(g), i.e., every 5 years. South Dakota never adopted a plan 

to address the requirements of 40 CFR 51.306 for a reasonably attributable visibility 

impairment long-term strategy; therefore, a Federal Implementation Plan (FIP) was 

promulgated to incorporate by reference the reasonably attributable visibility impairment 

long-term strategy requirements described in 40 CFR 52.29. See the federally-approved 

South Dakota Identification of Plan section at 40 CFR 52.2179(c). At tiiis time, it is not clear 

from a national perspective how to coordinate a reasonably attributable long-term strategy 

FIP with a regional haze long-term strategy SIP. The simplest approach would be for you to 

develop your own reasonably attributable long-term strategy to replace the FIP. Is this 

approach something you would consider? We would be happy to work with you to develop 

appropriate language and believe it would not take too much additional work given the effort 

you have already put into the draft regional haze SIP. 

26. Section 8.1, Class I Areas in Other States Impacted by South Dakota, p. 105: This section 

must quantify South Dakota's impact to the Class I areas outside the State (similar to that 

noted in Table 6-4). 

27. Section 8.3, Technical Basis for Modeling, Monitoring and Emissions Information, p. 106: 

To assist the reader, please include website addresses and/or references to where these 

technical analyses are housed and how they will be maintained going forward. In addition, 

the text must address DENR's commitment to continued compilation and analysis of the 

technical requirements for the Regional Haze SIP, regardless of future uncertainty in the 

Westem Regional Air Partnership's (WRAP's) role. 

28. Section 8.5, Factors in Developing Long Term Strategy, p. 107: There appear to be 

typographical errors in the last paragraph - should be "emissions reductions." 

29. Section 8.5.1, Emission Reductions from Ongoing Air Pollution Control Programs, 

pp. 107-108: As noted in comment #22 above, please clarify that although some of the cited 

Administrative Rules of South Dakota were not written specifically to address visibility 

impairment, they do control emissions of pollutants that may ultimately contribute to 

visibility impairment. 

30. Section 8.5.2, Measures to Mitigate Impacts of Construction Activities, pp. 108-109: 

South Dakota never adopted a plan to address the original Visibility New Source Review 

(NSR) requirements of 40 CFR 51.307; therefore, a Federal Implementation Plan (FIP) was 

promulgated to incorporate by reference the Visibility NSR requirements described in 

40 CFR 52.28. See the federally-approved South Dakota Identification of Plan section at 

40 CFR 52.2179(b). Is it your intention to replace the nonattainment NSR visibility analysis 

requirements of 40 CFR 52.2179(b) witii your proposed revisions to ARSD 74:36:21? If so, 

we would provide input for such a revision if requested. 

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31. Section 8.5.5, Smoke Management, pp. 109-110: Given that your source apportionment 

analysis identified organic carbon mass as one of the largest contributors on the most 

impaired days, it is difficult to understand why DENR has deferred consideration of smoke 

management techniques until 2013. In establishing its long-term strategy, the State must 

consider smoke management techniques for agricultural and forestry management purposes 

including plans as currentiy exist within the State for these purposes 

See 40 CFR 51.308(d)(3)(v)(E). At least some preliminary steps, in coordination with the 

FLMs, must be included, along with citing to any existing South Dakota buming provisions. 

32. Section 8.5.6, Enforceable Emission Limits and Control Measures, pp. 110-111: We note 

your intention to establish the Big Stone I BART limits and control measure requirements in 

either a construction permit or the Title V permit. Note that any air quality permit used to 

address BART requirements will need to be incorporated into the SIP. The South Dakota 

draft construction permit program regulations are currently under review by our office. Until 

this has been approved into the SIP, it will not be appropriate to rely upon the program for 

your BART permits. 

33. Section 9.0, Monitoring Strategy, p. 113-116: South Dakota never adopted a plan to address 

the original Visibility Monitoring requirements of 40 CFR 51.305; therefore, a FIP was 

promulgated to incorporate by reference the Visibility Monitoring requirements described in 

40 CFR 52.26. See the federally-approved South Dakota Identification of Plan section at 

40 CFR 52.2179(b). Is it your intention to replace the South Dakota Visibility Monitoring 

FIP requirements of 40 CFR 52.2179(b) with the DENR Monitoring Strategy as outlined in 

Section 9.0 of the Regional Haze SIP? If so, we would provide input for such a revision if 

requested. 

34. Section 10.2, Consultation with Other States, pp. 118-119: For clarity, it would be helpful if 

in each instance of consultation, the text identified the dates and outcomes of the discussions. 

In addition, other than their involvement in WRAP, does DENR have a plan to include tribal 

consultation on the public comment version of the SIP? 

35. Section 10.3, Public Input, p. 119: As noted in comment #23 above, the SIP must provide 

the public with a calculation of the number of years required to reach natural conditions if the 

RPG provides a slower rate of improvement than that needed to attain natural conditions by 

2064 per 40 CFR 51.308(d)(l)(ii). We understand your concerns regarding assumptions for 

other states included in the WRAP analysis; however, this SIP must include your best 

estimate of number of years to reach natural conditions with the proposed RPGs. 

36. Section 11.2, Report Every 5 Years, p. 121: As part of continuing consultation required 

under 40 CFR 51.308(i)(4), please clarify item 7, regarding the monitoring strategy, to note 

that you will consult with EPA and the FLMs on any revisions deemed necessary. 

37. Appendices: We are unable to comment on any of the appendices since they were not 

included. Information in these appendices may have been necessary for a more thorough 

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review by EPA. If you are able to share the draft appendices prior to the official public 

comment period, it would be very helpftil. 

38. ARSD Chapter 74:36:21, Regional Haze Program: 

(A) 74:36:21:02, Definitions: The definition of "BART-eligible source" must cite to an 

existing stationary facility as defined in 74:36:21:03. The definition of "visibility 

impairment" does not mirror the federal definition contained in 40 CFR 51.301 and must be 

revised accordingly. The definition of "contribute to visibility impairment" is not appropriate 

in the regional haze context and must be removed since there is no threshold for such a 

contribution. Finally, the definition of "major source" must cite to 40 CFR 51.166, and you 

must include the definition of "major modification" from 40 CFR 51.166, since the definition 

of major stationary source under the regional haze regulations includes major modifications. 

(B) 74:36:21:04, Visibility Impact Analysis: This section must be revised to clarify that the 

existing provisions of 74:36:09, Prevention of Significant Deterioration, are not replaced by 

this new section 74:36:21:04. Given that you do have existing regulations, what is your 

intent with this new provision? 

(C) 74:36:21:07, Operation and Maintenance of Controls: To improve clarity, this section 

should include more detail, such as specifying the minimum criteria for an acceptable 

operation and maintenance plan and when the source specific operation and maintenance plan 

to meet such criteria shall be submitted for permitting authority approval. 

(D) 74:36:21:08, Monitoring, Recordkeeping and Reporting: As this provision is drafted, the 

term "main stack" is a concem because it is not clear whether all of the sulfur dioxide and 

nitrogen dioxide emissions firom the BART-eligible source will be routed to the main stack. 

The term "main stack" implies the presence of other stack(s) which is/are not equipped with 

continuous emission monitoring system(s) as is the "main stack." The language in 

74:36:21:08 (page 8, second sentence) should be revised to read, "All sulfur dioxide and 

nitrogen dioxide emissions from the BART eligible source shall be routed to the main stack 

of the BART-eligible source. Monitoring of sulfiir dioxide and nitrogen dioxide emissions 

from the main stack shall be conducted using a continuous emission monitoring system 

which complies with continuous emission monitoring system requirements in 74:36:13." 

(E) 74:36:21:11, Federal Land Manager Notification and Review: As required by the 

Regional Haze Rule, the Federal Land Managers must be provided a 60-day consultation 

period prior to any public hearing on the Regional Haze SIP. Since a BART permit is an 

integral part of the Regional Haze SIP, this 60-day consultation period must extend to FLM 

BART permit review as well. In addition, since any BART permit must be incorporated into 

the Regional Haze SIP, the 30-day public notice for the SIP needs to identify the inclusion of 

any BART permits. 

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